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OFAC General License

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On March 20, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) extended the expiration dates of two general licenses related to GAZ Group (“GAZ”), which was designated as an SDN on April 6, 2018 for being owned or controlled by Oleg Deripaska. Please see our blog post regarding this designation here, and our blog about the previous extension of these general licenses here. At the same time, OFAC expanded one of the…

On March 5, 2020, pursuant to Executive Order 13851 of November 27, 2018 and the Nicaragua Human Rights and Anticorruption Act of 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) further escalated sanctions against Nicaragua by naming the Nicaraguan National Police (“NNP”) and three NNP commissioners as Specially Designated Nationals (“SDNs”), citing serious human rights abuses. OFAC previously named other officials of the NNP as SDNs in 2018 and 2019, also citing…

On February 27, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Counter Terrorism and Iran-related General License No. 8 (“GL 8”) together with new frequently asked questions (“FAQs”) about the general license and the Swiss Humanitarian Trade Arrangement (“SHTA”). New GL 8 authorizes US Persons and non-US entities owned or controlled by US Persons to engage in Iran-related humanitarian transactions even if the CBI is directly or indirectly involved.…

On November 5, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Venezuela-related general license (General License No. 35) (“GL 35”) to authorize certain administrative transactions with the Government of Venezuela (“GOV”) prohibited by Executive Order (“EO”) 13884 (“Blocking Property of the Government of Venezuela”); issued General License No. 34A (“GL 34A”), which supersedes and replaces General License No. 34, and authorizes transactions involving certain GOV-related individuals prohibited by EO 13884; and identified five current GOV officials on the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to EO 13884.

Then, on November 21, 2019, OFAC announced the amendment of the Venezuela Sanctions Regulations (“VSR,” 31 C.F.R. Part 591) to incorporate additional EOs; make certain clarifying changes; add a GL authorizing US Government activities; and add an interpretive provision regarding activities related to judicial processes.  The VSR regulatory amendments took effect on November 22, 2019 concurrent with their publication in the Federal Register, available here.

These Venezuela sanctions developments are described in more detail below.  Our previous blog posts about US sanctions targeting Venezuela are available here.